With the ending on Sept. 17, 2015, of the congressional review period for the historic accord reached between Iran and the E3/EU+ 31 countries (the Joint Comprehensive Plan of Action or JCPOA), which restricts Iran’s nuclear program in return for the easing of nuclear-related sanctions, U.S. and foreign-based businesses are wondering to what extent the Iran market is now open for business and how they will be impacted by the deal. This article analyzes how the sanctions regime will be changed by the accord and what, if any, impact it will have on various industries dealing with Iran. Perhaps surprising to some, the deal will have only limited impact on U.S. businesses as the main relief of U.S. sanctions will be focused on non-U.S. Persons. Foreign businesses will have few restrictions and will be well positioned to take advantage of Iran’s almost untapped market.
Law Before Implementation
To understand how the law will change after the implementation of the accord, it is helpful to understand the current state of the sanctions regime. The sanctions against Iran that were the subject of the above-noted negotiations are made up of a combination of U.S. sanctions, both congressional and executive actions, as well as European Union and United Nations Security Council sanctions.
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